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20120416AVU to Clearwater Paper 1-10.pdf
Jean Jewell From: Kimball, Paul [Paul.Kimball@avistacorp.com ] Sent: Wednesday, April 11, 2012 11:48 AM To: 'peterrichardsonandoleary.com'; 'greg©richardsonandoleary.com'; 'dreadingmindspring.com' Cc: Andrea, Michael; Kalich, Clint; Ehrbar, Pat; Jean Jewell; donald.howellpuc.idaho.gov ; krisine.sasserpuc. idaho.gov ; dwalkeridahopower.com ; lnordstrom©idahopower.com ; kaufmann@lklaw.com ; danial.solanderpacificorp.com ; 'joe@mcdevitt-miller.com '; nelson@thnelson.com ; iravenesanmarcos©yahoo.com ; gregmimuralaw.com ; 'billpiske@cableone.net ; ronwilliamsbradbury.com ; wthomas@dynamisenergy.com ; smd@idahowaters.com ; olmstead@tfcanal.com ; robertapau108gmail.com ; jcarkulis@exergydevelopment.com ; arronesq@aol.com ; blueribbonenergy©gmail.com ; nscanal@cableone.net; bdbrown@frontiernet.net ; ted@tsorenson.net; glennienvisionwind.com ; margaret©envisionwind.com ; meganrnp.org ; 'botto@idahoconservation.org '; 'kmiller©snakeriveralliance.org'; rkahnnippc.org ; don.sturtevant©simplot.com ; marv.lewallenclearwaterpaper.com Subject: Avista's Responses to Clearwater Paper Corporation Production Requests Attachments: CW_PR1 Attachment A - Avoided Cost Calculation With DSM_ Without CO2_1 12811 _ (handedout December 1 5).xlsx; CW_PR_1 Attachment B - Avista IRP Method Avoided Costs 12-15-2011 .pdf; CW_PR_1 .docx; CW_PR_2 Attachment A.xlsx; CW_PR_2.docx; CW_PR_3 Attachment A - Updated Avoided Cost Calculation—With DSM_ Without CO211281 1 .xlsx; CW PR 3.docx; CW PR 4.docx; CW_PR_5.docx; CW_PR 6.docx; CW PR 7.docx; CW PR 8 Attachment A.xlsx; CW PR 8.docx; CW PR 9.docx; CW PR 10.docx April 11, 2012 Richardson & O'Leary, PLLC 2) - 111 o 515 N 27th Street Boise, ID 83702 rn Attn: Peter Richardson Gregory Adams Production Request of Clearwater Paper Corporation in Case No. GNR-E-11-03 Attached are Avista's responses in connection to Clearwater Paper production requests in the above referenced docket. Included in this email are Avista's responses to the following Production Requests: 1 through 10. Hard copies of Avista's responses were mailed today, 04/11/12. If there are any questions regarding the information, please contact Michael Andrea at (509) 495-2564 or via e- mail at michael.andrea@avistacorp.com Thank you, Paul Kimball Senior Regulatory Analyst State & Federal Regulation Avista Corporation 1411 E. Mission Ave, Box 3727 Spokane, WA 99220-3727 (509) 495-4584 direct (509)368-0141 cell paul.kimball@avistacorp.com AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 4/9/2012 CASE NO: GNR-E-1 1-03 WITNESS: Clint Kalich REQUESTER: Clearwater RESPONDER: Clint Kalich TYPE: Production Request DEPARTMENT: Energy Resources REQUEST NO.: CW-1 TELEPHONE: (509) 495-4532 REQUEST: Please provide a copy of the handout the Company provided at the meeting to present and discuss IRP Models at the Idaho Public Utilities Commission on December 15, 2011. Include all work papers, spreadsheets in electronic format with formulas intact, and model outputs used in producing the handout. RESPONSE: The handout and associated working papers are attached. The specific files are: CWPR1 Attachment A - Avoided Cost Calculation —With DSM_ Without CO2112811 (handed out December 15) CW_PR_l Attachment B - Avista IRP Method Avoided Costs 12-15-2011 In preparing this response, Avista discovered a discrepancy between the presentation and the spreadsheet. The capacity payment for base load resources was shown to be $1 0.07/MWh when the actual value calculated in the spreadsheet was $11.02. AVISTA CORPORATION JURISDICTION: CASE NO: REQUESTER: TYPE: REQUEST NO.: RESPONSE TO REQUEST FOR INFORMATION IDAHO DATE PREPARED: 4/9/2012 GNR-E-1 1-03 WITNESS: Clint Kalich Clearwater RESPONDER: Clint Kalich Production Request DEPARTMENT: Energy Resources CW-2 TELEPHONE: (509) 495-4532 REQUEST: For each of the five QF configurations presented in Table 3 of Clint Kalich's Direct Testimony, please provide all work papers, spreadsheets in electronic format with formulas intact, and model outputs used in producing the values found in Table 3. For each of Company's gas-fired generation plants, please provide a list of the annual capacity factor, by year, beginning in 2013 through the end of the 20 year analysis period found in the model runs for each of the five QF configurations. RESPONSE: The working papers are included in the File "CW_PR_2 Attachment A." There were no CCCT plant runs performed for this analysis. Therefore Avista is unable to respond to this portion of the request. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 4/9/2012 CASE NO: GNR-E-1 1-03 WITNESS: Clint Kalich REQUESTER: Clearwater RESPONDER: Clint Kalich TYPE: Production Request DEPARTMENT: Energy Resources REQUEST NO.: CW-3 TELEPHONE: (509) 495-4532 REQUEST: If the Company were to offer a Qualifying Facility (QF) with IRP Methodology contract pricing utilizing the methodology in effect on the date of this request, please state if the assumptions in the calculation would be consistent with the assumptions included in the 2011 IRP filed with the Idaho Public Utilities Commission on August 25, 2011 (AVU-E-1 1-04). Please provide the following inputs that would be used in calculating IRP Methodology rates and indicate if the inputs are consistent with the 2011 IRP: (a)Natural gas fuel forecast, (b)Firm load forecast, (c)Resource stack, and (d)Forecast of the year and month of first future peak load deficit. RESPONSE: Avista uses an "IRP Methodology" to calculate negotiated rate prices. Being a methodology, Avista uses it as such and updates key assumptions that might have changed significantly since its publication. Changes can include natural gas prices, the load forecast, and changes in our resources and contract (including new QF purchases) obligations. Since the 2011 IRP, each of the above-mentioned assumptions have changed, reflecting the recent fall in natural gas prices, reduced loads, and new power supply contracts including the Palouse Wind farm. These changed assumptions may be found by reviewing the file entitled "CW_PR_3 Attachment A - Updated Avoided Cost Calculation —With DSM_ Without CO2_1 128 11.xlsx" which is attached. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 4/9/2012 CASE NO: GNR-E-1 1-03 WITNESS: Clint Kalich REQUESTER: Clearwater RESPONDER: Clint Kalich TYPE: Production Request DEPARTMENT: Energy Resources REQUEST NO.: CW-4 TELEPHONE: (509) 495-4532 REQUEST: Reference the Company's Preferred Resource Strategy set forth in the 2011 IRP (Table 1, p. viii), including plans to acquire an 83 MW SCCT in 2018. Please provide the prices the Company would offer a QF that would provide power in the same configuration as the SCCT. In other words, please run the projected output of the 83 MW SCCT through the Company's IRP Methodology as though it were a QF requesting contract pricing. RESPONSE: Avista has not performed this analysis and it is not clear how such analysis would be performed based on the information provided in this production request because much of the information necessary to provide an estimate has not been provided (e.g., timeframe of deliveries, location). However, it provides an excellent example of the importance of a negotiated PURPA rate. Hypothetically, because a SCCT would not be expected to run for any significant number of hours during a year, likely a capacity payment would need to be negotiated, along with some availability testing to ensure the project would be available to generate during peak utility load hours. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO CASE NO: GNR-E-1 1-03 REQUESTER: Clearwater TYPE: Production Request REQUEST NO.: CW-5 DATE PREPARED: 4/9/2012 WITNESS: Clint Kalich RESPONDER: Clint Kalich DEPARTMENT: Energy Resources TELEPHONE: (509) 495-4532 REQUEST: Reference the Company's Preferred Resource Strategy set forth in the 2011 IRP (Table 1, p. viii), including plans to acquire an 83 MW SCCT in 2018. Please provide the assumptions regarding expiring contracts in developing this resource portfolio. Did the Company include the Clearwater Paper QF in its resource portfolio past the time of expiration of the existing contract in 2013? Please explain the impact on Avista's future resource needs under the assumption the Clearwater Paper QF is not available to Avista after expiration of the contract in 2013. RESPONSE: As detailed in Table 2.5 of Avista's 2011 IRP (page 2-20), a total of approximately 253 MW of winter capacity will expire between now and 2018. In the 2011 IRP, the Clearwater Paper contract was assumed to continue past its expiration in 2013 due to its nature, and the fact that some assumption must be made. However, and as explained in the response to Production Request 3, for the purposes of a negotiated rate calculation, various assumptions are updated. Therefore, when the Clearwater Paper PURPA contract (or any other expiring PURPA contract) rate is negotiated, the resource is removed from the tabulation of the Company's load and resource balance, thereby pushing the utility into deficit sooner and enabling capacity payments sooner than if the contract was assumed to continue. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO CASE NO: GNR-E-1 1-03 REQUESTER: Clearwater TYPE: Production Request REQUEST NO.: CW-6 DATE PREPARED: 4/9/2012 WITNESS: Clint Kalich RESPONDER: Clint Kalich DEPARTMENT: Energy Resources TELEPHONE: (509) 495-4532 REQUEST: According to the Commission's accepted "IRP Methodology' (IPUC Order No. 26576, JPC-E- 95-9) and IPUC Staff Witness Rick Sterling's direct testimony Exhibit 101, "the avoided cost of the QF project is the difference in the present value of the revenue requirements (PVRR) between the base case resource plan and a modified resource plan that includes the QF resource." (Exhibit 101, JPC-E-95-9, R. Sterling, page 14.) Please explain in detail how the Company incorporates the "revenue requirement" as it would in filing for a certificate of public convenience and necessity (i.e. return of and on investment, all taxes, etc.) in the calculation of rates offered to QFs. RESPONSE: Under the IRP Methodology, assumptions are first reviewed and updated where appropriate (e.g., natural gas, loads and resources). Where assumptions affecting the wholesale marketplace have changed (e.g., natural gas) the AURORA IRP model is re-run and Avista's PRiSM model is updated with the new wholesale market data (i.e., value of the new generation resource options). The Company then runs two new PRiSM runs to determine the capacity and energy values. In the first new PRISM run, the capacity component of the QF resource is added to the load and resource tabulation (L&R). The difference between the two economic values (i.e., revenue requirement between the pre-QF PRiSM run and PRiSM run containing the QF capacity) determines the avoided capacity value available for the QF contract. A second PRISM run is then performed where both the expected capacity and energy contributions of the QF resource are added to the L&R. The difference between the first PRISM run and the second PRISM run determines the energy payments available to the QF contract. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO CASE NO: GNR-E-1 1-03 REQUESTER: Clearwater TYPE: Production Request REQUEST NO.: CW-7 DATE PREPARED: 4/9/2012 WITNESS: Clint Kalich RESPONDER: Clint Kalich DEPARTMENT: Energy Resources TELEPHONE: (509) 495-4532 REQUEST: Reference the Direct Testimony of Clint Kalich, p. 9, stating, "For example, canal hydro operates during the spring and summer months, with no output during the winter. Avista's wind rating is low due to the lack of wind diversity in its portfolio." Please list the wind projects that are in Avista's portfolio and indicate the location, MW nameplate, expected energy output, the date the contract was signed, and the on-line date of each. RESPONSE: Avista's only wind resource is a 35-MW share (of nameplate) of the Stateline wind project located in Oregon. The contract was signed in 2004 and runs into 2014. On average Avista expects 9 aMW from this resource. Avista entered into a contract with First Wind for the Palouse Wind Project on June 28, 2012. The approximately 105 MW (58-turbine) project is expected to enter commercial service in the fall of 2012 and generate 40 aMW near Oakesdale, WA. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 4/9/2012 CASE NO: GNR-E-1 1-03 WITNESS: Clint Kalich REQUESTER: Clearwater RESPONDER: Clint Kalich TYPE: Production Request DEPARTMENT: Energy Resources REQUEST NO.: CW-8 TELEPHONE: (509) 495-4532 REQUEST: For each of the five QF configurations presented in Table 4 on page 25 of Clint Kalich's Direct Testimony, please provide all work papers, spreadsheets in electronic format with formulas intact, and model outputs used in producing the values found in lines 8, 9, and 10. In the column titled "Note." please explain fully the source of the noted SAR lines 2, 6, 7, 8, 9, and 10. ISXF!li The working papers are included in the File "CW_PR_8 Attachment A." The notes are self-explanatory. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 4/9/2012 CASE NO: GNR-E-1 1-03 WITNESS: Clint Kalich REQUESTER: Clearwater RESPONDER: Clint Kalich TYPE: Production Request DEPARTMENT: Energy Resources REQUEST NO.: CW-9 TELEPHONE: (509) 495-4532 REQUEST: Reference the Direct Testimony of Clint Kalich, pp. 13-14, stating: It is often true that utilities are surplus in early years; being so is an essential part of providing reliable utility service. It also is true that QF developers would be affected by these surpluses were they to receive lower early-year payments during surplus years. But this effect is a reflection of true avoided costs. It is not reasonable to hold a utility system short both of capacity and reliability simply to promote QF development. Given the "lumpiness" of utility generation investment, please explain in detail how a QF development would ever, over time, receive compensation equal to what it costs a utility to build a resource if it is denied capacity payments during surplus periods. RESPONSE: Acquisition lumpiness does not necessarily mean that a QF resource will get more or less value. A QF could, because of its size, receive a payment greater than were it to have to follow the acquisition schedule of a larger "utility-scale" resource. For example, it is possible that a utility would defer the acquisition of a larger utility-scale resource until such time that the deficit being met is closer to the size of the resource being acquired. In the interim period the market might be relied upon to meet energy and capacity needs. However, when the QF valuation is made, the QF resource would be paid for capacity in those years prior to the future acquisition where the utility is deficit. AVISTA CORPORATION RESPONSE TO REQUEST FOR INFORMATION JURISDICTION: IDAHO DATE PREPARED: 4/9/2012 CASE NO: GNR-E-1 1-03 WITNESS: Clint Kalich REQUESTER: Clearwater RESPONDER: Clint Kalich TYPE: Production Request DEPARTMENT: Energy Resources REQUEST NO.: CW-10 TELEPHONE: (509) 495-4532 REQUEST: Assume that an existing QF requested IRP Methodology pricing for the time frame after expiration of its existing contract. Please describe how Avista would treat the expiring contract in the IRP Methodology rate calculations. Would Avista include the output from the existing QE contract in its assumed base case resource plan past the date of expiration of the contract? Please explain the basis for the treatment of the expiring contract. RESPONSE: In this example, Avista would remove the expiring QF resource from its L&R tabulation before calculating avoided cost rates. This removal would tend to make our acquisitions sooner and payments of capacity to the QF resource larger (depending of course on the QF resource being of a size large enough to affect our L&R position).